Dispute avoidance

Proactive approach

• Certainty can be achieved by utilising the rulings procedures that exist in a number of countries.
• We can also offer advice on the most effective strategy to pursue, and provide tax advice, technical economics and support in any forum, including examination, administrative appeals, advance pricing agreements or litigation. We have a wide network of professionals that are used to working with tax audit on a national and international basis.

Advance Pricing Agreements

Advance pricing agreements (APAs) are advance agreements on transfer pricing methodologies, entered into by a multinational taxpayer and at least one government’s administration. Although APAs are styled as "advance" agreements, in fact they are often coupled with the resolution of pending transfer pricing issues from prior years. Therefore, APA procedures can provide the opportunity to resolve transfer pricing issues over the past five years or more, as well as those of future years.

The PwC advantage

Our transfer pricing team has broad experience in helping clients obtain APAs. Our strong international network means that we can assist you in any jurisdiction in which you require support, and we can help you coordinate this approach cross-border, as necessary.